Psychiatrists Urged to Review HCP Prescriptions to Patients

On October 6—less than two weeks away--hydrocodone combination products (HCPs) will no longer be classified as Controlled Substance Schedule III (C-IIs), but rather as Controlled Substance Schedule II (C-IIs), in accordance with the Drug Enforcement Administration's (DEA) final rule to reschedule such products. The new requirements that will impact prescribers are as follows:

• Prescriptions for HCPs must be written on a hard copy, original prescription or electronically transmitted where e-prescribing of C-IIs by certified e-prescribers is allowed by state law and the pharmacy is certified to accept electronically prescribed controlled substances. Fax transmission is not allowed.


• Prescriptions for HCPs cannot be called into a pharmacy.


• Prescriptions issued after October 6 for HCPs cannot be refilled.

The DEA notes that prescriptions issued before October 6 that have authorized refills may be dispensed in accordance with DEA rules for refilling, partial filling, transferring, and central filling Schedule III through Schedule V controlled substances until April 8, 2015. However, certain states and pharmacy systems may not honor this exemption, and therefore will not allow remaining refills to be dispensed for HCP prescriptions written prior to October 6.

In the meantime, APA members should seek out information concerning their respective state laws as it relates to the new prescription practices for HCPs as a Schedule II substance and notify patients with HCP prescriptions of the new federal requirements to obtain prescriptions after October 6. To avoid the possibility that medically necessary refills will not be dispensed between October 6 and April 8, 2015, members should consider providing patients with new Schedule II-compliant prescriptions.

Read the DEA’s final ruling in The Federal Register at http://go.usa.gov/mc8d.